G.R. No. 101083 July 30, 1993
JUAN ANTONIO, ANNA ROSARIO and JOSE ALFONSO, all surnamed OPOSA, minors, and represented by their parents ANTONIO and RIZALINA OPOSA, et al., and THE PHILIPPINE ECOLOGICAL NETWORK, INC., petitioners,

vs.
THE HONORABLE FULGENCIO S. FACTORAN, JR., in his capacity as the Secretary of the Department of Environment and Natural Resources, and THE HONORABLE ERIBERTO U. ROSARIO, Presiding Judge of the RTC, Makati, Branch 66, respondents.

FACTS

The petitioners, all minors duly represented by their parents and joined by the Philippine Ecological Network, Inc. (PENI), filed a taxpayer’s class suit before the Regional Trial Court (RTC) of Makati. The suit was filed for themselves, for others similarly situated, and on behalf of future generations. They sought to prevent the misappropriation or impairment of Philippine rainforests. The complaint alleged that the Philippines’ forest cover had drastically decreased from 16 million hectares (53% of land mass) 25 years prior to a mere 850,000 hectares of virgin forest (2.8% of land mass) at present, due to the granting of Timber License Agreements (TLAs). It detailed numerous environmental tragedies resulting from deforestation, including water shortages, erosion, loss of flora and fauna, and climatic changes. The petitioners asserted their constitutional right to a balanced and healthful ecology. They demanded the cancellation of all existing TLAs and for the Secretary of the DENR to cease accepting, processing, renewing, or approving new ones. The respondent Secretary filed a Motion to Dismiss on the grounds that the complaint stated no cause of action and raised a political question. The RTC granted the motion to dismiss. The petitioners then filed the instant special civil action for certiorari under Rule 65 of the Rules of Court, challenging the RTC’s dismissal order.

ISSUE

Whether or not the petitioners have a cause of action to seek the cancellation of Timber License Agreements and a halt to their processing/renewal, based on their asserted right to a balanced and healthful ecology.

RULING

Yes. The Supreme Court granted the petition, reversed the RTC’s order of dismissal, and remanded the case for trial on the merits.
1. The petitioners have a cause of action. The complaint sufficiently alleges a specific legal right (the right to a balanced and healthful ecology under Section 16, Article II of the Constitution), a corresponding duty on the part of the respondent DENR Secretary (to protect and advance that right), and an act or omission by the respondent in violation of that duty (the continued allowance of TLAs which impair the rainforests). The Court held that this right is self-executing and judicially enforceable, conferring a legal right upon the petitioners.
2. The case does not present a political question. The duty of the courts to protect constitutional rights is a legitimate function of the judiciary. The Court’s role is to determine whether the respondent agency has acted within the limits of its authority or in grave abuse of discretion, which is a justiciable issue.
3. The petitioners have legal standing (locus standi). As taxpayers and citizens asserting a constitutional right to a healthful ecology, and given the paramount public interest involved and the intergenerational nature of the injury alleged, the petitioners have a sufficient interest to file the suit. The Court recognized the concept of “intergenerational responsibility,” stating that every generation has a responsibility to the next to preserve that right.
4. The allowance of a taxpayer’s class suit is proper. The subject matter is of common and general interest to all citizens, and the parties are so numerous that it is impracticable to bring them all before the court.
5. The doctrine of exhaustion of administrative remedies does not apply. The respondent Secretary’s denial of the petitioners’ final demand letter rendered any further administrative appeal futile. Furthermore, the issue raised is purely legal, and the actions complained of are allegedly committed by the department head himself.